Last Updated and Effective as of: June 30, 2023
Our primary Kids Site is kids.scholastic.com. Our mobile applications (“apps”) for Kids are also Kids Sites, and covered by this policy.
"Kid" or "child" means a user under the age of 13.
"Parent" means a kid's parent or legal guardian.
“Sites” mean web sites, mobile applications (or apps) or other online services operated by Scholastic Inc. and/or its affiliates. “Sites” does not include our educational technology products licensed to educational institutions and educators.
Activities on our Kids Sites
Children do not have to give us more information than reasonably necessary to use our Kids Sites. Activities on our Kids Sites include virtual worlds, games, polls/multiple choice quizzes, filtered chat, filtered story-telling, tracking reading minutes, Kids accounts and friending.
Information Kids May Submit
Email Addresses: To use the interactive features of our Kids Site, a child picks an anonymous user name from a list and creates a password. Children are not required to submit an email address to use our Kids Sites, but some features are only available if a child provides an email address (such as community tools), and some features may be enhanced if the child submits an email address (such as games).
If ae child chooses to submit an email address, we send the child one email to confirm receipt. Then we hash the email address (that is, we change it into a series of values instead of text). After that, the email address is used only to help the child retrieve or re-set their account, using the same hashing process to match the hashed email address against our records. If the child’s account is found, we send instructions in a one-time email to the matched address.
Email addresses may also be collected for customer service, e-cards or other content-sharing tools, or for parental consent or notification. See also Parental Consent and Retention and Deletion.
Community Features: All content Kids give us for public posting, such as in chats, forums, commenting tools or writing activities, is filtered or moderated to remove inappropriate content and Kids’ Personal Information before it is made public. Our Kids Sites may allow Kids to “friend” each other, so Kids can see each other’s game progress and postings, but Kids cannot see each other’s Kids’ Personal Information or send each other private messages.
Geolocation: Our Kids Sites may collect general geolocation information (but no more specific than city or zip code), such as in a library look-up tool. That general geolocation information is not stored with any other information about the user.
Date of Birth: We may collect birth date from children for purposes of age-screening. We do not keep birth date after the age-screening process.
Information We Collect Automatically
When children visit our Kids Sites, certain information may be collected automatically. We use this information to maintain, secure, analyze and improve our Kids Sites.
Information collected automatically includes:
· Internet protocol (IP) address – a string of numbers assigned to a computer when it connects to the internet
· General geolocation information (derived from IP address and no more specific than zip code)
· Navigation information – what users do on our Site, sometimes the website they came from
· General systems, browser, domain and internet service provider information
The technology used to automatically collect this information includes:
· Cookies: Cookies are small data files sent by a website or app to be saved on a user's computer or device. Cookies can help us recognize a user and save their preferences for when they return to our Kids Site, and also help with age-screening tools.
· Local storage: Local storage or local shared objects, such as Unity 3D WebGL Cache, may be stored on a computer or device through a media player or other software installed on that computer or device. Local storage and local shared objects help us recognize users when they come back. They are often used in activities like games, to store scores or progress.
· Pixel tags: A pixel tag (also known as a "clear GIF" or "web beacon") is a tiny image that can be placed on a Web page or in emails to users, to tell us when a user has displayed that page or opened those emails.
These tools may allow us to assign a unique number to our child users, but this number will not be used to track child users across different, unaffiliated web sites.
Most browsers can be set to detect or reject browser cookies. You may be able to change settings in your device or browser to reject local storage or local shared objects. Some parts of our Kids Sites may be harder to use or may not work at all if cookies, local storage or local shared objects are rejected.
For more information about cookies, go to https://www.allaboutcookies.org/.
How We Use Kids’ Personal Information
We may use and disclose Kids’ Personal Information: (1) to provide our services to a child (such as the games and activities your child would like to play); (2) to comply with the law or legal process (such as when we use Kids’ Personal Information for record-keeping to satisfy legal and compliance obligations); (3) in accordance with valid consent (where a parent has provided consent for their child); and (4) as necessary for business interests (such as when we collect and use a child's data in support of internal operations, taking into account the impact on the child's privacy, or for security purposes).
We use service providers to help us run our Kids Sites. Our service providers can only use Kids’ Personal Information to do the tasks we hire them to do, in the ways we allow them to, such as enabling registration, maintaining accounts, fulfilling account requests, and customer service. Our service providers cannot use Kids’ Personal Information for any other reason, and we require them to maintain the confidentiality, security and integrity of Kids’ Personal Information.
Behaviorally Targeted Advertising
Our Kids Sites do not track Kids to serve them behaviorally targeted advertisements (also known as retargeting or online behavioral advertising), or to allow others to do so.
Special Circumstances for Information Disclosure
We reserve the right to disclose information, including Kids’ Personal Information, collected from a child:
· In connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets, wind-down of business or related due diligence. To the extent required by law, we will get parental consent before disclosing children's Kids’ Personal Information under such circumstances, and will obtain the agreement of any applicable third party to maintain the confidentiality, security and integrity of that Kids’ Personal Information.
Our Kids Sites maintain reasonable technical and organizational standards to help ensure that Kids’ Personal Information is secure, including encryption. However, no Internet site or service can guarantee 100% security, so it is possible that someone could unlawfully access Kids’ Personal Information despite our efforts.
When we knowingly collect Kids’ Personal Information from a child, we ask the child's parent for consent before we collect it, unless the collection and/or use falls within an exception under COPPA, such as where we use an email address to respond directly to a one-time request from the child or for password retrieval or reset. We let parents know about such collection as required or permitted by law.
When prior parental consent is required, we ask for it in ways allowed by COPPA. For example, if Kids’ Personal Information will be used only by us, we may ask for the parent's consent by email. While we do not currently, and do not expect to, use Kids’ Personal Information in this manner, if Kids’ Personal Information would be disclosed on the Kids Site or disclosed to a third party besides a service provider, we would obtain a consent from the parent as required by law, such as by a form to be returned via U.S. mail or electronic scan, or consent obtained in connection with a credit card purchase.
Parental Choices and Controls
If you are a parent of one of our child users, you can ask us to:
· Allow you to review your child’s Kids’ Personal Information
· Deactivate your child's Kids Site account
· Revoke any consent you have given for your child
· Delete Kids’ Personal Information your child has given us
· Stop collecting Kids’ Personal Information from your child
To make these requests, or if you have any other questions about our Kids Sites or our policies or practices regarding the collection, use, or disclosure of Kids’ Personal Information, you may contact us at:
Scholastic Inc. (attn: General Counsel)
New York, NY 10012
Email – Customer Service: email@example.com
Email – Privacy: firstname.lastname@example.org
Parents may also print, complete and return this letter to the specified address.
We may require additional information to identify your child’s account or to verify your identity and relationship with the child.
Retention and Deletion
If we do collect Kids’ Personal Information, we keep that information for the time we determine is necessary to perform the task for which we collected it, unless otherwise requested by a child’s parent. We reserve the right to keep certain information necessary for record-keeping to the extent permitted and/or required by law, including any statutory retention requirements. When deleted, Kids’ Personal Information is deleted securely. In some cases we may de-identify Kids’ Personal Information instead of deleting it.
Other Web Sites, Apps and Services
We recommend reading the privacy policies of each web site visited after leaving our Kids Sites, to learn about how information is treated by others.
We encourage parents and teachers to talk with their children and students about how to be safe online. For more information on protecting your child online, please visit OnGuard Online.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents (“Notice”) is information we are required to provide you under the California Consumer Privacy Act (“CCPA”). This Notice applies solely to residents of California and applies to personal information (as defined in the CCPA) from or about Kids collected through the Kids Site (“Personal Information”).
In the past 12 months, we have collected the following Personal Information from or about children through the Kids Sites (“Kids’ Personal Information”):
· Identifiers: such as email address, username, IP address, and cookie IDs.
· Internet or other electronic network activity information: such as the “Information We Collect Automatically,” as described above.
· Location Information: general geolocation data (such as zip code-level location inferred from IP address).
· Information that children may post or otherwise provide to the Kids Sites.
In the past 12 months, we have collected and disclosed the above categories of Kids’ Personal Information for our business purposes such as:
· To provide our services;
· To enable a service provider to provide us with its services;
· To maintain the safety and integrity of the Kids Site, and to protect the rights, property, or safety of a child, ourselves, or others;
· To comply with applicable law and legal process; and
· In accordance with valid consent.
We do not “sell” Kids’ Personal Information or “share” Kids’ Personal Information collected through the Kids Sites, as these terms are defined in the CCPA, and we have not done so within the past 12 months.
California residents have certain rights. A parent can request on their child’s behalf that we:
· Provide the categories of Kids’ Personal Information we have collected or disclosed about the child in the last 12 months, the categories of sources of such information, the business or commercial purpose for collecting such information, and the categories of third parties to which we disclosed such information (most of which is already provided above);
· Provide access to and/or a copy of certain Kids’ Personal Information;
· Delete certain Kids’ Personal Information; and
· Correct inaccurate Kids’ Personal Information.
As noted above, we do not “sell” or “share” (as defined in the CCPA) Kids’ Personal Information.
California residents may have the right to receive information about any financial incentives we offer, and the right not to be discriminated against (as provided under California law) for exercising the rights above.
In addition, if you are under 18, and a registered user of the Kids Sites, you may ask us to remove content or information that you have posted to the Kids Site by writing to email@example.com. Please include a description of the content you would like removed, and if possible, the URL for the site and the name of the feature where the content was posted. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
These rights are subject to limitations and exceptions. If you ask to exercise one of these rights, you (or your Parent, as the case may be) may need to verify your identity before we can fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you (and, if you are a minor, your Parent), for the agent to act on your behalf. You will still need to verify your identity directly with us.
To exercise these rights, please contact us using one of the methods above in the section titled “Parental Choices and Controls.”
“Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share children’s personal information with third parties for their own direct marketing purposes.
DATA PROCESSING IN THE UNITED STATES